1. IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT,
IN AND FOR BROWARD COUNTY, FLORIDA
LINDA SMITH,
Plaintiff,
vs.
Civil Action No. XXXXXXXXXX
SAM JOHNSON, and
KEVIN ROBERTS,
Defendants.
_________________________________/
ANSWER TO CIVIL COMPLAINT
COMES NOW Defendant, KEVIN ROBERTS (“Defendant Roberts”), by and through
his attorneys and for his answer to Plaintiff’s Civil Complaint does state and allege as follows:
1. Defendant Roberts admits the allegations contained in paragraph 1 of Plaintiff’s Civil
Complaint.
2. Defendant Roberts admits the allegations contained in paragraph 2 of Plaintiff’s Civil
Complaint.
3. Defendant Roberts admits the allegations contained in paragraph 3 of Plaintiff’s Civil
Complaint.
4. Defendant Roberts admits the allegations contained in paragraph 4 of Plaintiff’s Civil
Complaint.
5. Defendant Roberts admits the allegations contained in paragraph 5 of Plaintiff’s Civil
Complaint.
6. Defendant Roberts admits the allegations contained in paragraph 6 of Plaintiff’s Civil
Complaint.
7. Defendant Roberts denies having sufficient knowledge or belief to respond to the allegations
of paragraph 7 in the complaint, therefore denies those allegations, and demands strict proof
thereof.
8. Defendant Roberts denies the allegations contained in paragraph 8 of Plaintiff’s Civil
Complaint.
9. Defendant Roberts denies the allegations contained in paragraph 9 of Plaintiff’s Civil
Complaint.

2. 10. Defendant Roberts denies the allegations contained in paragraph 10 of Plaintiff’s Civil
Complaint.
11. Defendant Roberts denies the allegations contained in paragraph 11 of Plaintiff’s Civil
Complaint.
12. Defendant admits and denies certain allegations or statements in paragraph 12 in Plaintiff’s
civil complaint. Defendant admits Plaintiff sustained dog-bite injuries. Defendant denies the
dog broke lose from the doghouse and attacked Plaintiff.
13. Defendant Roberts denies the allegations contained in paragraph 13 of Plaintiff’s Civil
Complaint.
14. Defendant Roberts denies the allegations contained in paragraph 14 of Plaintiff’s Civil
Complaint.
15. Defendant Roberts denies the allegations contained in paragraph 15 of Plaintiff’s Civil
Complaint.
16. Defendant Roberts denies having sufficient knowledge or belief to respond to the allegations
of paragraph 7 in the complaint, therefore denies those allegations, and demands strict proof
thereof.
17. Defendant Roberts denies the allegations contained in paragraph 17 of Plaintiff’s Civil
Complaint.
18. Defendant Roberts denies the allegations contained in paragraph 18 of Plaintiff’s Civil
Complaint.
WHEREFORE, Defendant Roberts prays that this court enter judgment against Plaintiff and
award Defendant Roberts his costs as allowed by law and for such other and further relief as may
be proper in the premises.
DATED this 15th
day of January 2016.
_________________________________________
James Gettim
Sueem and Gettim Attorneys at Law
411 Las Olas Blvd. Suit 301.
Fort Lauderdale, Florida 33301
FL Bar No. 783108472
Attorney for Defendant Kevin Roberts